Social Security Evaluation of Multiple Impairments

Courts have held that the listings "may not be mechanically applied where multiple disabilities and subjective complaints are concerned."[i] The best "combination" arguments at Step 3 involve multiple diseases which impact each other.  See, for example, the guidance in SSR 02-1p.

Obesity affects the cardiovascular and respiratory systems because of the increased workload the additional body mass places on these systems.  Obesity makes it harder for the chest and lungs to expand.  This means that the respiratory system must work harder to provide needed oxygen.  This in turn makes the heart work harder to pump blood to carry oxygen to the body.  Because the body is working harder at rest, its ability to perform additional work is less than would otherwise be expected.  Thus, we may find that the combination of a pulmonary or cardiovascular impairment and obesity has signs, symptoms, and laboratory findings that are of equal medical significance to one of the respiratory or cardiovascular listings.

Here is another example of the combined effects of impairments supporting an equivalence assessment.

Suppose the claimant is afflicted with a heart condition that does not, in itself, result in the level of fatigue requires to meet the medical listing at 4.00.  The claimant also suffers from diabetes, which is only partially controlled, resulting in bouts of lethargy and dizziness because of jumps in blood sugar levels.  Neither impairment meets the appropriate listing, but, in combination, they are equivalent in severity to medical listing 4.02.[ii]

In fact, these same effects of uncontrolled diabetes correlate well to episodic impairments, as noted above, and can equal a seizure listing.  Note also that diabetics may experience “silent ischemia” and may equal 4.04.[iii]

[i] Monteer v. Schweiker, 551 F. Supp. 384, 390 (W.D. Mo. 1982)

[ii] Social Security Disability and the Legal Professional, Jeffrey Scott Wolf, Lisa B Proszek,  Note: The symptoms of chronic heart failure used to be listed in 4.02A but are now located at 4.00D2b(i)

[iii] Listing 4.00E7